Revenue eBrief No. 025/23
01 February 2023
Charges on income for corporation tax purposes
Tax and Duty Manual Part 08-02-01 – Charges on income for corporation tax purposes – has been updated as follows:
- In section 2.2, to refer to the treatment contained in Tax and Duty Manual Part 08-03-06 for relief from withholding tax provided for by double taxation treaties.
- In section 3.4, to clarify that where a merger or division involves the dissolution of the investing company or the investee company, the fundamental conditions for relief, as provided by section 247 Taxes Consolidation Act 1997 will not be satisfied and relief will cease to be available.